This is an audio case brief of United States v. Youts, 229 F.3d 1312 (10th Cir. 2000). The audio brief provides a full case analysis. However a written summary of the case is provided below.
In the early morning hours of January 10, 1994, after an evening of misadventure, Abner Youts and Richard Nesbitt needed a ride home. The pair set out on foot and ended up at the Union Pacific Railyard in Wichita, Kansas, where they boarded two idling locomotives that were connected together. After playing with the controls, they figured out how to move the trains back and forth. Mr. Youts remarked to Mr. Nesbitt that, as a boy, he had always loved trains and wanted to be an engineer. Mr. Youts then decided to drive the train home.
Upon arriving at a point on the tracks approximately half a block from his house, Mr. Youts stopped the train, let Mr. Nesbitt off, and decided to send the train back through town, driverless. He put the train into reverse at full throttle and disembarked. The train got as far as a curve in the tracks in downtown Wichita. The normal speed for this curve is ten miles per hour. The driverless train however, took it at fifty-six miles per hour and then derailed. One locomotive car ended up lying in the street and the other landed on its side in the dirt next to the tracks. Although no one was hurt, the derailment caused Union Pacific and the City of Wichita a total of $ 234,145 in damage and clean-up costs.
As a result of anonymous tips to the Wichita Crimestoppers hotline, investigating authorities learned Mr. Nesbitt and Mr. Youts may have been involved in the offense. Eventually, Mr. Nesbitt gave a confession that detailed their activities on the evening in question and the two men were each indicted on one count of violating 18 U.S.C. § 1992, the federal train wreck statute. Mr. Nesbitt pled guilty and agreed to testify against Mr. Youts. The case against Mr. Youts was tried before a jury, which found him guilty. He was sentenced to 46 months in prison and ordered to pay $ 234,145 in restitution.
Mr. Youtes appealed his conviction. Mr Youtes argued that 18 U.S.C, the statute under which he was charged required a showing of specific intent to wreck the train, and the evidence of his specific intent was insufficient to support the jury’s determination of guilt.
The federal train wreck statute punishes anyone who “willfully derails, disables, or wrecks any train, engine, motor unit, or car used, operated, or employed in interstate or foreign commerce by any railroad.
The issue before the court is whether a statute which charge a defendant with a mens rea of willfulness should be read to require proof specific intent.
Under the Model Penal Code, knowing conduct is sufficient to establish willfulness. A requirement that an offense be committed willfully is satisfied if a person acts knowingly with respect to the material elements of the offense. And a person acts knowingly with respect to a material element of an offense when, … if the element involves a result of his conduct, he is aware that it is practically certain that his conduct will cause such a result. The natural, probable consequences of an act can satisfactorily evidence the state of mind accompanying it.
That showing has been met here. The natural, probable, and practically certain consequence of sending a driverless locomotive down curving tracks at full speed will be the result punished by the statute. Mr. Youts knowingly set in motion – literally and figuratively – the events which caused the train to wreck.
Yout’s conviction was affirmed.